2026-05-17 · 6 min read

The DOJ Title II Rule Is Real: What Your Government Website Must Do by April 2027

The Rule Is Final — and Most Agencies Are Treating It Like a Suggestion

On April 24, 2024, the Department of Justice published a final rule that closes a gap that has existed under the ADA for decades: state and local governments must now make their web content and mobile applications meet WCAG 2.1, Level AA ^[1]. This is not a pilot program or a voluntary framework. It is a binding federal regulation, and the compliance clock has been running since the day it was signed.

When we work with government IT teams, we find the same pattern repeatedly. Leadership has heard there is a deadline. They believe remediation is someone else's problem — accessibility coordinator, vendor, or general counsel. What they almost never know is what the rule actually mandates, what the extended deadline changed (and what it did not), or which jurisdictions have less time than they think.

This post closes that gap. We are going to tell you exactly what the rule requires, what the extension actually says, and what agencies that get this right do differently.

What the Rule Actually Requires

The mandate is technical and specific. State and local governments must conform to WCAG 2.1 Level AA ^[6]. That standard, published by the W3C, comprises 50 success criteria organized across four principles: Perceivable, Operable, Understandable, and Robust ^[6].

Conformance means all of them. Not a subset, not an 80% pass rate on an automated scanner. The rule does not define a scoring threshold — it defines a standard. An agency is either in compliance or it is not.

What does WCAG 2.1 AA cover in practice? The criteria include making images understandable for screen reader users, ensuring forms are labeled properly, providing captions for video, making keyboard navigation fully functional without a mouse, meeting minimum contrast ratios, and ensuring that dynamic content changes — modals, alerts, carousels — are announced to assistive technology. These are not edge cases. They are the core interaction patterns of every government website we have audited.

The rule covers web content AND mobile apps. An agency cannot remediate its public website and ignore its constituent-facing mobile application. Both must meet the standard.

The Extension: What Changed and What Did Not

The DOJ extended the compliance deadlines in April 2026. Here is precisely what changed ^[2]:

Jurisdictions with a total population of 50,000 or more had an original deadline of April 24, 2026. That date has been extended to April 26, 2027 ^[2]. Smaller jurisdictions and special districts had an original deadline of April 24, 2027; their date is now April 26, 2028 ^[2].

The word "extension" is doing a lot of work in vendor conversations right now, and we have seen it cause real harm. Agencies hear "extension" and interpret it as "the situation changed." The situation did not change. Deque, the organization that maintains axe-core, put it plainly after the April 2026 announcement: the key takeaway is to keep going ^[5]. The rule's technical requirements are unchanged. The underlying legal obligation under Title II of the ADA is unchanged. The extension is a compliance date adjustment, not a scope reduction.

We would add one thing Deque did not say: the year between now and April 2027 is not a gift. It is exactly long enough for an agency that starts today to complete an inventory, prioritize high-traffic pages, run a full audit, manage vendor remediation cycles, and verify the result. We know because we have run this sequence with agencies. Twelve months sounds like a long time until you are three months in and your CMS vendor has a six-week queue.

Who Is Actually Subject to This Rule

The rule applies to entities that qualify as "public entities" under Title II of the ADA — state governments, local governments, and their instrumentalities. Counties, municipalities, transit authorities, school districts, water utilities, and similar entities all fall under this definition.

The population threshold in the extension applies only to the timing of the deadline, not to whether the entity is covered. A jurisdiction with 12,000 residents is still covered by the rule — they simply have until April 2028 rather than April 2027. We see this misread often: small agencies conclude the rule "doesn't apply to them yet" when what it actually says is that they have more time.

Special districts — park districts, library districts, sanitation authorities — follow the smaller-jurisdiction timeline regardless of the underlying population of the area they serve. That is worth verifying explicitly with your agency's legal counsel before assuming a later date applies.

What the DOJ Expects You to Have Done Already

The ADA.gov guidance lays out specific first steps the DOJ expects agencies to have taken as early preparation ^[3]. These include inventorying your web content, establishing an accessibility policy, designating a coordinator, creating a complaint process, and beginning remediation on high-impact pages.

The DOJ also published a small entity compliance guide specifically for agencies that lack dedicated accessibility staff or legal resources ^[4]. That guide is worth reading in full. It is direct about what the department considers adequate preparation versus what it considers insufficient.

What we find when we engage with agencies partway through this process is that the inventory step is consistently underestimated. An agency may believe it operates "a website," but what it actually operates is a patchwork of a primary CMS, a separate permits portal, a legacy procurement system, a GIS mapping interface, several third-party embedded tools, and a PDF library accumulated over fifteen years. Each of those has its own compliance posture, and each is covered by the rule.

What WCAG 2.1 AA Conformance Actually Takes

We do not want to understate this: achieving WCAG 2.1 AA conformance on a mature government website is a project, not a configuration change.

The work typically breaks into four phases. First, audit — a credible audit runs both automated scanning and manual testing with assistive technology. Automated scanners catch a meaningful fraction of issues; they cannot catch everything because some criteria require human judgment. Second, prioritization — not every page carries equal risk. High-traffic pages, constituent service portals, and any page that is the only available channel for a service get remediation priority. Third, remediation — this is where most of the calendar goes. Vendor coordination, CMS template updates, PDF remediation, third-party widget replacement. Fourth, verification — confirm the fixes hold under real assistive technology, not just the scanner that passed the fix.

The agencies that are positioned well for April 2027 are the ones that started in early 2025. The agencies that are starting now have enough time if they move without delay.

The Practical Next Step

If you are an IT director or CIO at a state or local agency, the most useful thing you can do this week is two things.

Run an automated scan of your highest-traffic pages. It will not tell you everything, but it will tell you whether you have obvious, systematic issues — missing alt text on every image, unlabeled forms throughout your site, missing document language declarations. Those patterns are the sign of a site that has never been evaluated against the standard.

Then call your accessibility coordinator, your general counsel, or your CMS vendor and ask a direct question: what does our documented plan look like for April 2027 conformance? If you cannot get a direct answer, that is the answer.

We run WCAG audits for state and local government agencies through Parallax, our accessibility SaaS built specifically for government procurement cycles. If your agency needs a credible audit with documentation that holds up to DOJ scrutiny, we know how to run it.

Morton Technology Consulting LLC — WCAG 2.1 AA audits for Florida government agencies. Parallax audit → · WCAG Readiness Kit → · All posts →